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Accuracy-Related Penalty
Year Deficiency Under Sec. 6662(a)
2000 $8,223 $1,644.60
2001 3,657 731.40
The issues remaining for decision are:
(1) Should we sustain respondent’s determination for each of
the years at issue that the expenditures that petitioners made
during each such year on certain properties must be capitalized
and amortized? We hold that we should.
(2) Should we sustain respondent’s determination that
petitioners are liable for each of the years at issue for the
accuracy-related penalty under section 6662(a)? We hold that we
should.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time petitioners filed the petition in this case,
they resided in Columbus, Nebraska (Columbus).
At times not disclosed by the record during 2000 and 2001,
petitioners made expenditures for certain work that they had done
on two rental properties that they owned on 40th Street and 8th
Street, respectively, in Columbus (40th Street property and 8th
Street property).
Petitioners timely filed Form 1040, U.S. Individual Income
Tax Return, for each of their taxable years 2000 (2000 return)
and 2001 (2001 return).
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Last modified: November 10, 2007